Finding Text
Finding 2022-01 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Eligibility Federal Program - AL no. 93.461 COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment and Vaccine Administration for the Uninsured. Pass-through Entities - N/A Federal Agency - U.S. Department of Health and Human Services Federal Award Number and Award Year - No award number, award year 10/1/2021 ? 9/30/2022 Criteria - Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Eligibility? The COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment and Vaccine Administration for the Uninsured program reimburses health care-related expenses attributable to COVID-19 testing for the uninsured and treatment of uninsured individuals with COVID-19. Reimbursement includes COVID-19 testing and testing related items, COVID-19 treatment and COVID-19 vaccine administration fees. The Health Resources and Services Administration (HRSA) FAQ document specifies that COVID-19 must be the primary reason for treatment or for vaccine administration along with the patient being uninsured. Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition and Context - KPMG identified 7 patients out of 40 samples (18%) tested in which reimbursement was requested for the patient visit even though the visit was not identified in the patient record as COVID-19 being the primary reason for treatment. KPMG identified 2 patients out of 40 samples (5%) tested in which reimbursement was requested for the patient visit even though the patient had active insurance coverage and thus fully insured for the date of service reimbursed. Possible Cause and Effect - In discussing these unallowable costs and eligibility conditions with the Center, they stated that claims were not appropriately allocated between reimbursable COVID-10 tests and non-reimbursable visits using a non-COVID-19 primary diagnosis code and these claims were not effectively reviewed prior to submission to HRSA. Questioned Costs - Known questioned costs of $204,199. Statistically Valid Sample - The sample was not intended to be, and was not, a statistically valid sample. Repeat of Prior Finding - No Recommendations - We recommend that management review its current processes for entering and reviewing diagnosis codes and eligibility requirements to ensure proper codes are documented for all services in accordance with the federal award programs terms and conditions and therefore the patient is eligible for services. View of Responsible Official - Management agrees with the noted finding. Additionally, management established a work group to review inpatient and outpatient accounts incorrectly billed to HRSA to ensure the amounts were properly refunded. The refund process for overbillings is expected to be completed in the fourth quarter of 2023. Further, the HRSA program has ended and the Center is no longer billing for these services.